ML15292A013
| ML15292A013 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim (DPR-035) |
| Issue date: | 10/20/2015 |
| From: | Entergy Nuclear Generation Co |
| To: | Office of Nuclear Reactor Regulation |
| Venkataraman B | |
| References | |
| Download: ML15292A013 (11) | |
Text
Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400
Agenda
- Introduction of Participants
- Background and History
- Problem Statement
- Proposed Resolution
- Basis for Change
- Intended Actions
- NRC Staff Questions and Perspective
- Conclusions 2
Introduction of Participants
- NRC Staff
- Entergy - Pilgrim 3
Background and History
- July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
- Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
- 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
- Immediate actions; RP Tech added back to shifts; 4
Problem Statement
- Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.
5
July 14, 2006 Letter: Chem Tech Training 6
Proposed Resolution
- Entergy proposal:
o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation
- Entergy has concluded this change is acceptable 7
Basis for Change Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs OE review identified similar implementations February 5, 2007 NRC Staff letter concluded:
o Previous Entergy proposal met requirements of:
10CFR50.47(b)(2) - adequate staffing provided
10CFR50, App E, IV.A - organization for coping o
Chem Tech training considered an enhancement o
No decrease in effectiveness / no NRC approval required 8
Intended Actions
- Conference call with NRC Staff
- Preparation and submittal of request for prior NRC Staff review and approval
- Revise training
- Revise ERO staffing 9
NRC Staff Questions and Perspective 10
Conclusions 11
- Proposed change in Chemistry Technician is appropriate based on ERO assignments
- Proposed change is justified by staffing study
- Entergy intends on submitting the proposed change for prior NRC review and approval
Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400
Agenda
- Introduction of Participants
- Background and History
- Problem Statement
- Proposed Resolution
- Basis for Change
- Intended Actions
- NRC Staff Questions and Perspective
- Conclusions 2
Introduction of Participants
- NRC Staff
- Entergy - Pilgrim 3
Background and History
- July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
- Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
- 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
- Immediate actions; RP Tech added back to shifts; 4
Problem Statement
- Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.
5
July 14, 2006 Letter: Chem Tech Training 6
Proposed Resolution
- Entergy proposal:
o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation
- Entergy has concluded this change is acceptable 7
Basis for Change Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs OE review identified similar implementations February 5, 2007 NRC Staff letter concluded:
o Previous Entergy proposal met requirements of:
10CFR50.47(b)(2) - adequate staffing provided
10CFR50, App E, IV.A - organization for coping o
Chem Tech training considered an enhancement o
No decrease in effectiveness / no NRC approval required 8
Intended Actions
- Conference call with NRC Staff
- Preparation and submittal of request for prior NRC Staff review and approval
- Revise training
- Revise ERO staffing 9
NRC Staff Questions and Perspective 10
Conclusions 11
- Proposed change in Chemistry Technician is appropriate based on ERO assignments
- Proposed change is justified by staffing study
- Entergy intends on submitting the proposed change for prior NRC review and approval